Practical Transfer Pricing Checklists for Businesses, Tax Professionals and Multinational Groups
Transfer Pricing compliance involves much more than preparing a benchmarking study or maintaining documentation. Businesses must identify related parties, understand transaction flows, perform functional analysis, select appropriate transfer pricing methods, maintain documentation, and ensure ongoing compliance with evolving regulatory requirements.
This Transfer Pricing Checklists Library has been designed as a practical resource to help businesses assess their Transfer Pricing readiness, identify compliance gaps, and prepare for tax authority reviews and audits.
To support businesses, tax professionals, finance teams, advisors, and students, we regularly review and monitor guidance issued by international organizations, tax authorities, and regulatory bodies across multiple jurisdictions.
The resources listed below represent some of the widely recognized transfer pricing references that may be relevant for understanding transfer pricing concepts, documentation requirements, benchmarking methodologies, dispute resolution mechanisms, and compliance obligations in various jurisdictions.
Transfer Pricing Checklists Library
1. Related Parties Identification Checklist
Before any Transfer Pricing analysis begins, businesses should identify all Related Parties.
Checklist
☐ Direct shareholders identified
☐ Indirect shareholders identified
☐ Subsidiaries identified
☐ Parent companies identified
☐ Sister companies identified
☐ Joint ventures identified
☐ Common control arrangements identified
☐ Significant influence relationships identified
☐ Ownership percentages documented
☐ Organizational chart updated
☐ Related Party register maintained
☐ Cross-border relationships identified
2. Connected Persons Checklist
Particularly important in jurisdictions with Connected Person rules.
Checklist
☐ Directors identified
☐ Shareholders identified
☐ Partners identified
☐ Owners identified
☐ Senior management identified
☐ Family member relationships assessed
☐ Payments to Connected Persons identified
☐ Compensation arrangements documented
☐ Commercial rationale documented
☐ Arm’s Length Principle assessment performed
3. Controlled Transactions Identification Checklist
Checklist
☐ Sale of goods identified
☐ Purchase of goods identified
☐ Service transactions identified
☐ Management fees identified
☐ Royalty payments identified
☐ Licensing arrangements identified
☐ Financing transactions identified
☐ Guarantees identified
☐ Cost allocations identified
☐ Shared service arrangements identified
☐ Business restructuring transactions identified
☐ Intangible transfers identified
4. Functional Analysis Checklist
Checklist
☐ Business model understood
☐ Key value drivers identified
☐ Revenue-generating activities documented
☐ Operational responsibilities identified
☐ Strategic functions identified
☐ Decision-making functions identified
☐ Supply chain documented
☐ Business processes mapped
☐ Key personnel identified
☐ Intercompany interactions documented
5. FAR Analysis Checklist
Functions, Assets and Risks Analysis
Functions
☐ Procurement functions identified
☐ Manufacturing functions identified
☐ Distribution functions identified
☐ Marketing functions identified
☐ Management functions identified
☐ R&D functions identified
Assets
☐ Tangible assets identified
☐ Intangible assets identified
☐ Human capital identified
☐ Technology assets identified
Risks
☐ Market risk assessed
☐ Credit risk assessed
☐ Inventory risk assessed
☐ Foreign exchange risk assessed
☐ Product liability risk assessed
☐ Operational risk assessed
☐ Financial risk assessed
6. DEMPE Analysis Checklist
Development, Enhancement, Maintenance, Protection and Exploitation
Checklist
☐ Development activities identified
☐ Enhancement activities identified
☐ Maintenance functions identified
☐ Protection functions identified
☐ Exploitation activities identified
☐ Legal ownership documented
☐ Economic ownership assessed
☐ Key decision makers identified
☐ Funding arrangements reviewed
☐ Intangible-related risks assessed
7. Benchmarking Study Checklist
Checklist
☐ Tested transaction identified
☐ Tested party selected
☐ Industry analysis completed
☐ Search strategy documented
☐ Comparable companies identified
☐ Comparable transactions identified
☐ Screening criteria documented
☐ Rejection criteria documented
☐ Financial data reviewed
☐ Multi-year analysis considered
☐ Final comparable set documented
☐ Benchmarking report prepared
8. Comparability Analysis Checklist
Checklist
☐ Product comparability assessed
☐ Functional comparability assessed
☐ Asset comparability assessed
☐ Risk comparability assessed
☐ Geographic comparability assessed
☐ Industry comparability assessed
☐ Economic conditions assessed
☐ Business strategies considered
☐ Material differences identified
☐ Comparability adjustments evaluated
9. Transfer Pricing Method Selection Checklist
Checklist
☐ Nature of transaction evaluated
☐ Internal comparables reviewed
☐ External comparables reviewed
☐ CUP Method considered
☐ Resale Price Method considered
☐ Cost Plus Method considered
☐ TNMM considered
☐ Profit Split Method considered
☐ Reliability assessed
☐ Most appropriate method selected
☐ Method selection documented
10. Arm's Length Price Determination Checklist
Checklist
☐ Method applied correctly
☐ Financial indicators selected
☐ Arm’s length range calculated
☐ Lower quartile determined
☐ Median determined
☐ Upper quartile determined
☐ Comparability adjustments applied
☐ Results tested
☐ Outliers reviewed
☐ Arm’s length conclusion documented
11. Financial Transactions Checklist
Checklist
☐ Intercompany loans identified
☐ Cash pooling arrangements reviewed
☐ Guarantees identified
☐ Interest rates reviewed
☐ Loan terms documented
☐ Credit risk assessed
☐ Borrower profile analyzed
☐ Lender profile analyzed
☐ Comparable financing data obtained
☐ Arm’s length interest rate determined
12. Intra-Group Services Checklist
Checklist
☐ Service provider identified
☐ Service recipient identified
☐ Services described
☐ Benefit test performed
☐ Shareholder activities identified
☐ Duplicative services assessed
☐ Allocation keys reviewed
☐ Cost base validated
☐ Mark-up assessed
☐ Supporting documentation maintained
13. Transfer Pricing Documentation Checklist
Checklist
☐ Related parties identified
☐ Controlled transactions documented
☐ Functional analysis completed
☐ FAR analysis completed
☐ Method selection documented
☐ Benchmarking included
☐ Financial information reconciled
☐ Intercompany agreements attached
☐ Supporting evidence maintained
☐ Documentation reviewed annually
14. Local File Checklist
Checklist
☐ Organizational structure included
☐ Business overview included
☐ Related party details included
☐ Transaction descriptions included
☐ Functional analysis included
☐ Transfer pricing method included
☐ Benchmarking study included
☐ Financial information included
☐ Agreements referenced
☐ Local File finalized
15. Master File Checklist
Checklist
☐ Group structure documented
☐ Business operations described
☐ Supply chain documented
☐ Intangibles ownership described
☐ Financing arrangements documented
☐ Transfer pricing policies documented
☐ Geographic footprint described
☐ Consolidated financial statements included
☐ Master File updated
16. Country-by-Country Reporting (CbCR) Checklist
Checklist
☐ MNE group status assessed
☐ Reporting threshold reviewed
☐ Constituent entities identified
☐ Revenue data collected
☐ Profit data collected
☐ Employee data collected
☐ Tax paid data collected
☐ Capital information collected
☐ CbCR notification requirements reviewed
☐ CbCR report prepared
17. Safe Harbour Checklist
Checklist
☐ Eligibility criteria reviewed
☐ Qualifying transactions identified
☐ Services assessed
☐ Cost base verified
☐ Applicable mark-up reviewed
☐ Documentation maintained
☐ Safe Harbour election requirements reviewed
☐ Annual compliance confirmed
18. Transfer Pricing Health Check Checklist
Checklist
☐ Related party register updated
☐ Intercompany agreements reviewed
☐ Benchmarking validity assessed
☐ Documentation status reviewed
☐ Profitability reviewed
☐ Transfer pricing risks identified
☐ Audit exposure assessed
☐ Corrective actions identified
☐ Compliance calendar updated
19. Transfer Pricing Audit Readiness Checklist
Checklist
☐ Documentation available
☐ Benchmarking studies updated
☐ Agreements executed
☐ Financial reconciliations completed
☐ Supporting evidence maintained
☐ Key personnel identified
☐ Audit response process established
☐ Historical positions reviewed
☐ Potential exposures quantified
20. Annual Transfer Pricing Compliance Checklist
Checklist
☐ New related parties identified
☐ New transactions reviewed
☐ Benchmarking refresh assessed
☐ Documentation updated
☐ Disclosure requirements reviewed
☐ CbCR obligations assessed
☐ Financial transactions reviewed
☐ Intercompany agreements updated
☐ Arm’s length pricing confirmed
☐ Management sign-off obtained
Disclaimer
This checklist library is intended solely for general informational and educational purposes and should not be considered tax, legal, accounting, or professional advice. Transfer Pricing requirements may vary by jurisdiction, industry, transaction type, and applicable regulations. Businesses should obtain professional advice tailored to their specific circumstances before relying on any checklist or implementing any Transfer Pricing position.
The inclusion of any publication, website, guideline, manual, regulation, or resource on this page should not be interpreted as an endorsement, affiliation, partnership, sponsorship, approval, or authorization by any government authority, tax authority, international organization, regulatory body, or third party.
Transfer pricing laws, regulations, administrative guidance, and interpretations may change over time. Users should always refer to the latest official publications and obtain professional advice before relying on any information for tax, legal, accounting, or business decisions.